650-653Rev0Comments

API Ballot Comments and Resolution

Ballot: 650-653Rev0 - Weld Spacing for Permanent Attachments

Proposal: Ballot ID: 1632

Date: April 21, 2023

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Voter Name(Vote)

Clause No./Subclause No./Annex(e.g. 3.1)

Type of Comment

Comment (justification for change) by the Voting Member Proposed change by the Voting Member

Comment Resolution

David Flight

DOW CHEMICAL

(Affirmative)

Proposed Change

Editorial Some of the Imperial dimensions do not have a Metric equivalent as the rest do.

Tad Broad

Fisher Tank Company

(Negative)

5.8.1.2 Technical Overall it is not feasible or warrented to MT or PT all temp or permanent attachements for non Group IV, IVA, V and VI materials. This will add substainal cost and time to projects. I know of no cases of underbead cracking in groups I, II, III or IIIA.

section 5.8.1.2.a. the term "provide external reinforcement from tank shell" is new to me and unclear why a 12" pad would be required.

5.8.1.2.a. "In addtion, the external permanent plate thickness shall be the smaller of 1/2" or the shell course thickness. The edge of any permanent attachment welds should be at least..." May also want to reference requirements of section 5.8.11.4 for pads over seams.

7.2.3.5 "the welds of permanent attachments ()and areas where temporary attachments are removed, shall be examined visually. Groups IV, IVA, V & VI shall also be tested by either the MT or PT method...

David Meaux

Fisher Tank Company

(Negative)

5.8.1.2 Technical The proposal states that the concern is for underbead cracking when using Class IV, IVA, V, and VI materials. The proposed changes, however, impose the reason for this concern on all classes of materials. Perhaps the reason why the Standard omitted spacing requirements for Class I, II, and III materials was because that the concern for underbead cracking was not present in these materials. In my opinion, to totally impose the same spacing requirements upon all classes of materials is excessively conservative. The only exception might be regarding the first course.

Do not delete the statement below (as proposed):

5.8.1.2 When attachments are made to shell courses of material in Group IV, IVA, V, or VI,

The group can discuss whether there are technically sound reasons to possibly include the bottom course in all or some of the lower classes of materials.

page 1 of 11API electronic balloting template/version April 2003





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Voter Name(Vote)


Type of Comment


Comment Resolution

David Meaux

Fisher Tank Company

(Negative)

5.8.1.2.a Technical I question the technical basis for the addition of the following statement:

If a permanent plate is intended to provide external reinforcement from the tank shell, the minimum external plate size shall be no less than 12 inches in dimension (i.e. the external plate may be circular, oblong, square, or rectangular in shape with a square or rectangular plate having a minimum radius of 2 inches on all four corners). The plate shall be rolled to the outside tank radius.

Leave out this statement or provide the technical basis justifying the 12" dimension. I presume that the proposed requirement that the plate be rolled to the outside tank radius is due to the 12" size, however, we can discuss.

David Meaux

Fisher Tank Company

(Negative)

5.8.1.2.a Editorial The words "or not to exceed" are unnecesary....be the smaller of ½” or not to exceed the shell course thickness, whichever is less

....be the smaller of ½” or the shell course thickness, whichever is less

David Meaux

Fisher Tank Company

(Negative)

7.2.3.5 Technical The proposed added requirement to require additional NDE methods of examination on all attachments, permanent and temporary, for Class I, II, and III materials in my opinion, is overly conservative

7.2.3.5 Permanent and temporary attachments (see 7.2.1.10 for information on shell-to-bottom welds) shall be welded with low-hydrogen electrodes. The welds of permanent attachments (not including shell-to-bottom welds) and areas where temporary attachments are removed, shall be examined visually. For Class IV, IVA, V, and VI materials, additional NDE methods, either the magnetic particle method or by the liquid penetrant method shall be used(see 8.2, 8.4, or 8.5 for the appropriate inspection criteria). When welding to Group IV, IVA, V, and VI materials both permanent and temporary






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Voter Name(Vote)


Type of Comment


Comment Resolution

attachments shall be welded in accordance with a procedure, that minimizes the potential for underbead cracking.

Nelson Acosta

HMT Inspection

(Affirmative)

Para. 7.2.3.5

Editorial Delete "comma" in last sentence. ".... shall be welded in accordance with a procedure that minimizes the potential for underbead cracking."

Jimmy Schroeder

Innovative Tank Solutions, LLC

(Negative)

5.8.1.2 Technical The indication is that there is a concern about movement of the shell under hydrostatic loading for all sizes of tanks. The requirements would apply even to a 10' diameter tank. The concern is for large diameter tanks and some of these requirements should not apply to smaller tanks.

Jimmy Schroeder


(Negative)

5.8.1.2.a Technical This states that a minimum of a 12" x 12" repad is required for all repads. The thickness is the thinner of 1/2" or the thickness of the shell. If you have a shell with 1/2" thickness and a 2x2 angle attached to a repad welded to that shell, the repad would be 1/2" thick 12" x 12". If the weld on the pad is closer than 3" to the horizontal seam, then you have to move the pad or increase the pad size by almost 6" in height to meet the weld spacing requirements. If the repad is not required for reinforcing the shell for loadings but only to meet some other requirement, does the repad have to meet the size and thickness requirements? Based on the requirements in this section all tanks of all sizes and materials with a spiral stairway might have to have the stairway attached to an inside stringer with standoffs from the shell. The stair treads could not be welded directly to the shell because you could not maintain the weld spacing requirements. A pad could not be welded to the shell because you could not maintain the 45 degree angle of incidence to both the horizontal and vertical shell joints that will be crossed. There also is the requirement that the welds be at least






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Voter Name(Vote)


Type of Comment


Comment Resolution

6" from the weld on a nozzle repad even though for an Appendix A tank most weld requirements are 2.5 times the shell thickness. This seems to be adding additional burdens on small tanks.

Since many times customers do not locate such things as pipe support clips until late in the project, the cost impact to come back and do additional inspection requirements due to clips or pads crossing seams could be significant.

Jimmy Schroeder


(Negative)

7,2,3,5 Technical The requirement that all permanent and temporary attachments be welded with low hydrogen electrode and that they all be inspected not only visually but also with magnetic particle method or liquid penetrant method is excessive when you are dealing with smaller tanks. Tanks fabricated from Group I steel is typically welded with E6010 rod not with low hydrogen rod. This should not be applied in this manner to these type of tanks. It causes increased cost that is not necessary.

Doug Bayles

Inserv Integrated Service Company LLC

(Negative)

Entire Section

Technical If welding of butt welded pressure containing parts can be welded without the use of low hydrogen electodes, then there is no reason for attachments to be welded with low hydrogen.

Also, the testing requirements for temporary or permanent attachments will increase the cost of tanks that can be erected with Group I, II or III materials and not neccesarily improve the quality of the finished tank.

I would recommend leaving these sections as they currently exist in the standard.

Earl Crochet

Kinder Morgan Terminals

(Affirmative)

Editorial As balloted "When welding to Group IV, IVA, V, and VI materials both permanent and temporary attachments shall be welded in accordance with a procedure, that minimizes the potential for underbead cracking."






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Voter Name(Vote)


Type of Comment


Comment Resolution

Remove the comma from after the word "procedure".

Laurence Foster

Marathon Oil Company LLC

(Negative)

8.5.1.2 Editorial The paragraph is too long and difficult to read. Break it up into multiple sections like a)weld spacing, b)rolling, c) crossing welds and d) splices. Renumber b) and c).

Laurence Foster


(Negative)

5.8.1.2.a Technical Shaping of plates is dependant on thickness and radius.

Replaced "the plate shall be rolled to the outside tank radius" with "Refer to Figure 6-1 for shaping of plates."

Laurence Foster


(Negative)

7.2.3.5 Technical I don't believe a good argument is made in the background secton on why rules are necessary for Groups I, II, III, and IIIA. The subgroup should consider whether this change is necessary.

Kenneth Erdmann

Matrix Service Company

(Negative)

5.8.1.2 Technical I do not feel there is justification to expand this spacing requirement to all materials and stress levels.

James McBride

Petrex, Inc.

(Affirmative)

7.2.3.5 Technical As stated the attachments shall be made using low-hydrogen electrodes only. This would lead one to believe that only stick (shielded metal arc welding or SMAW)is allowed for such attachments. I believe that both hard wire (gas metal arc welding or GMAW) and flux cored wire (flux core arc welding or FCAW) are used extensively in field welds and should be included here.

Change to the following "...shall be welded with low-hydrogen electrodes when using the manual welding process, and either the appropriate solid or flux cored wires when using the semi-automatic welding process. The wire chosen shall be based upon compatability with the base metals being joined."

John Lieb

Tank Industry

5.8.1.2.a Editorial Suggest this section be revised to clarify as per below wording. Clarification of the section equivalent to the wording suggested below will resolve my negative

a) Permanent attachments may be welded directly to the shell with fillet






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Voter Name(Vote)


Type of Comment


Comment Resolution

Consultants, Inc.

(Negative)

ballot. welds having a maximum leg dimension of 13 mm (1/2 in.). If a permanent plate is intended to provide external reinforcement of the tank shell, the minimum external plate width or length dimension shall be 12 inches. The external plate may be circular, oblong, square, or rectangular in shape. Square or rectangular plates shall have a minimum radius of 2 inches on all four corners, except for corners of a plate that abuts the tank bottom plate, top angle or a shell stiffener. The plate shall be rolled to the outside tank radius. In addition, the external permanent plate thickness shall be the lesser of ½” or the shell course thickness. The edge of any permanent attachment weld shall be at least 75 mm (3 in.) from the horizontal joint of the shell and at least 150 mm (6 in.) from the vertical joint, insert-plate joints, or reinforcing-plate fillet welds. Permanent attachment welds may cross shell horizontal or vertical butt welds, providing the welds are continuous within these limits and the angle of incidence between the two welds is greater than or equal to 45 degrees. Additionally, any splice weld in the permanent attachment shall be located a minimum of 150 mm (6 in.) from






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Voter Name(Vote)


Type of Comment


Comment Resolution

any shell weld unless the splice weld is prevented from intersecting the shell weld by acceptable modifications to the attachment.

John Lieb

Tank Industry Consultants, Inc.

(Negative)

5.8.1.2.a Editorial Suggest this section be revised to clarify as per below wording. Clarification of the section equivalent to the wording suggested below will resolve my negative ballot.

a) Permanent attachments may be welded directly to the shell with fillet welds having a maximum leg dimension of 13 mm (1/2 in.). If a permanent plate is intended to provide external reinforcement of the tank shell, the minimum external plate width or length dimension shall be 12 inches. The external plate may be circular, oblong, square, or rectangular in shape. Square or rectangular plates shall have a minimum radius of 2 inches on all four corners, except for corners of a plate that abuts the tank bottom plate, top angle or a shell stiffener. The plate shall be rolled to the outside tank radius. In addition, the external permanent plate thickness shall be the lesser of ½” or the shell course thickness. The edge of any permanent attachment weld shall be at least 75 mm (3 in.) from the horizontal joint of the shell and at least 150 mm (6 in.) from the vertical joint, insert-plate joints, or reinforcing-plate fillet welds. Permanent attachment welds may cross shell horizontal or vertical butt welds, providing






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Voter Name(Vote)


Type of Comment


Comment Resolution

the welds are continuous within these limits and the angle of incidence between the two welds is greater than or equal to 45 degrees. Additionally, any splice weld in the permanent attachment shall be located a minimum of 150 mm (6 in.) from any shell weld unless the splice weld is prevented from intersecting the shell weld by acceptable modifications to the attachment.

Randy Kissell

TGB Partnership

(Affirmative)

5.8.1.2 Editorial We need to metricate all dimensions. change

no less than 12 inches in dimension (i.e. the external plate may be circular, oblong, square, or rectangular in shape with a square or rectangular plate having a minimum radius of 2 inches on all four corners).

to

no less than 300 mm (12 in.) in dimension (i.e. the external plate may be circular, oblong, square, or rectangular in shape with a square or rectangular plate having a minimum radius of 50 mm (2 in.) on all four corners).

John Mooney 5.8.1.2.a Editorial If a permanent plate is intended to provide external "from" should be "for"






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Voter Name(Vote)


Type of Comment


Comment Resolution

(Affirmative) reinforcement from the tank shell, the minimum.....

David Rosenkrantz

Access Engineering, LLC

(YetToVote)

Technical 1) This seems to pertain only to plates welded to the outside of the tank shell. Should these requirements also apply to permanent attachment plates welded to the inside of the tank? or are permanent attachment plates on the tank inside excempt from these requirements?

2) I do not understand what "from the tank shell" means in the sentence "If a permanent plate is intended to provide external reinforcement from the tank shell, the ..."

3) The sentence describing weld spacing says that the permanent attachment welds shall be 3" from horizontal shell joints but need to be 6" from insert plate joints. Since insert plate joints often (almost always?) include horizontal joints, this has lead to confusion. Is it possible to clarify this?

Ronald Bailey

American Tank & Vessel, Inc.

(Negative)

Technical I DISAGREE WITH EXPANDING SUB PAR 7.2.3.5 TO INCLUDE GROUPS I-IIIA MATERIALS.I WAS INVOLVED IN THE ORIGINAL CREATION OF THIS PAR AND AGREED WITH OTHERS THAT THIS ISSUE IS A STRESS/STRAIN ISSUE THAT SHOULD ONLY APPLY TO THE "HIGHER STRENGTH" STEELS.

Steven Adolphsen

CBI Services

(NonVoter)

Technical Negative comments:

1. In the “background “section, the wording doesn’t make sense. Current proposal wording: “Currently API 650 does not address … and also include the possibility of underbead cracking on Groups IV, IVA, V and VI materials. “

Negative comments:

1.

Suggested wording:

“Currently API 650 does not address … and also include the possibility of underbead cracking






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Voter Name(Vote)


Type of Comment


Comment Resolution

Suggested wording:

2. API has NDE rules that limit the size of the underbead. What is the justification for making API more stringent (Has there been significant increase in cracking in Groups I,II AND III?

Affirmative comment:

1. In ‘purpose’ section, change “code” to read “Standard”.

on Groups (CHANGE “IV, IVA, V and VI “ to read ) I, II , AND III materials.

Affirmative comment:

1. In ‘purpose’ section, change “code” to read “Standard”.

Larry Hiner

Chicago Bridge & Iron Company(CB&I)

(NonVoter)

General Technical Negative - Weld spacing requirements for mild carbon steel is not needed, however, if provided, need not be as restrictive as for group IV thru VI materials.

If weld spacing must be provided:

For shell material Groups I, II, III, or IIIA, the edge of any permanent attachment welds shall preferably be 75 mm (3 in.) from each other, any shell joint, insert-plate joints, or reinforcing-plate fillet welds. Otherwise, the minimum distance between weld edges may be reduced to 25 mm (1 in.) provided undercut is eliminated at locations where the distance is less than 50 mm (2 in.)

Larry Hiner


General Technical Affirmative - As an extension to this agenda item - Weld spacing criteria for Appendix S tanks attachments should be the same as for basic group I thru IIIA materials. If the attachment weld spacing for group I thru IIIA materials is added, Appendix S in API 650, 620, and 653 should be comparable.






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Voter Name(Vote)


Type of Comment


Comment Resolution

(NonVoter)

Larry Hiner


(NonVoter)

General Technical Affirmative - As an extension to this agenda item - attachment weld spacing criteria for Appendix X tanks attachments should be the same as for basic group IV thru VIA materials.

Douglas Miller


(Negative)

5.8.1.2.a Technical I do not agree with this change. If we think that we must add some limits for materials I to III, then the spacings could certainly be smaller in these lower strength materials than for group IV to VI.

Douglas Miller


(Negative)

5.8.1.2.a Technical Regarding the new requirements for shape and dimensions of structural pad plates; Why do we need such a large minimum size of 12”? API 653 9.3.1.7 requires only 4”.

Douglas Miller


(Negative)

7.2.3.5 Technical Similarly, I don’t agree that we need to mandate low hydrogen electrode and MT for attachments to group I to III plate. Long standing practice uses E6010 even on the shell verts up to 1/2” thick, per section 7.2.1.10. Why would we demand something better for attachment welds?


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650-653Rev0Comments